V.R. DeAngelis M.D.P.C. & R.T. Domingo M.D.P.C., V. R. DeAngelis M.D.P.C., Tax Matters Partner, et al. - Page 62




                                       - 62 -                                         
          of the Federal estate tax, Dr. DeAngelis caused VRD/RTD to join             
          the STEP plan on December 30, 1993.  Drs. DeAngelis and Domingo             
          were told that their 1993 and 1994 payments to the STEP plan                
          would suffice to fund the future costs of providing life                    
          insurance benefits for the remainder of their lives and to                  
          provide future distributions of cash to them at the time of their           
          choosing.  From the beginning of their decision to participate in           
          the STEP plan, the participating doctors were most concerned                
          about the amounts of, and their ability to receive, their                   
          expected benefits from STEP.  In fact, Drs. DeAngelis and Domingo           
          requested calculations and illustrations showing how much they              
          would receive depending upon the number of years that                       
          contributions were made to the STEP plan.  Drs. DeAngelis and               
          Domingo also wrote to Mr. Katz for assurance that they would                
          receive their benefits and requested a written opinion from the             
          plan sponsor about how to characterize their planned departures             
          from their practices so as to meet the terms of the STEP plan as            
          written.  STEP advised the participating doctors on what to say             
          in order to get their promised benefits, and STEP assured the               
          doctors that a protocol was in place to ensure that they would              
          get their money as intended.  Because each of the participating             
          doctors’ PCs funded its own employee’s benefits under the STEP              










Page:  Previous  52  53  54  55  56  57  58  59  60  61  62  63  64  65  66  Next 

Last modified: March 27, 2008